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NOTE: Samples were taken within site boundary. Samples were principally soils, but in the BIC building and lagoon and landfill areas, samples possibly
include soil-like materials (e.g. sediment, debris, waste).

Surface Sample Location (Approximate*)

Area D

Area B

AreasC, D, A**

Closed Lagoon, Closed Landfill,
& Vicinity

Former Ball field Vicinity

BIC Building, Basement

AroundExistingBemberg Buildings

TowardSite Periphery

Background (Surface and Subsurface)

Number of Samples

18

6

5

3

9

2

Contaminants

Concentration -- parts per million (ppm) Note: Samples were not all analyzed for
the same constituents

* Some sample locations are approximate because
some source documents provided indefinite location descriptions.
** Only one sample taken in Area A
*** CNPS = Concentration Not Potentially Significant.
The concentration(s) detected is not potentially significant to public health.
The maximum concentration is shown in the table if the maximum value found
in any sample at a given location is greater than the comparison value for
that contaminant.
**** ND = Not detected above laboratory quantitation
limits
PAH = polycyclic aromatic hydrocarbons
CREG = cancer risk evaluation guide
RMEG = reference dose media evaluation guide
Estimated = evaluation guide estimated by ATSDR staff
EPA
Soil Screening value = values EPA established for soil to protect against
excessive migration from soil to groundwater and air

NOTE: THE PRESENCE OF AN EXPOSURE PATHWAY
IN THIS LIST DOES NOT IMPLY THAT THE EXPOSURE IS (OR WAS) SUBSTANTIVE OR
THAT AN ADVERSE HEALTH EFFECT IS LIKELY TO OCCUR OR HAS OCCURRED.

Table 3: (Continued) Summary -- Completed Exposure Pathways

PATHWAY NAME:

River sediment (off site)

Fish (off site)

Surface water (off site)

Source:

Bemberg, possibly others upstream and downstream

Bemberg, possibly others upstream and downstream

Bemberg, possibly others upstream and downstream

Medium:

Sediment

Aquatic biota

Surface water

Exposure Point:

On and off site

Off site

Off site

Exposure Route:

Skin contact, incidental ingestion

Ingestion

Skin contact

Incidental ingestion

Receptor Population:

Shoreline users, fishermen, swimmers

Area fishermen

Shoreline users, fishermen, swimmers

Exposure Period:

Past, present, future

Past, present, future

Past, present, future

Contaminants potentially
of public health interest

Table 2

copper, arsenic, cadmium, PCBs

Table 2

Evaluation Comments:

Exposure and concentrations are below levels
of health concern.

Concentrations in fish reported in 1983 15
miles downstream and associated exposure are below levels of health concern.
No sampling data are available for nearby fish. Termination of plant discharges
and also 1990's river water and sediment data indicate there is very little
likelihood that fish being caught now containe any significant site contaminants.

Past ammonia exposure and concentrations cannot
be evaluated. For other chemicals, exposure and concentrations are below
levels of health concern.

NOTE: THE PRESENCE OF AN EXPOSURE PATHWAY
IN THIS LIST DOES NOT IMPLY THAT THE EXPOSURE IS (OR WAS) SUBSTANTIVE OR
THAT AN ADVERSE HEALTH EFFECT IS LIKELY TO OCCUR OR HAS OCCURRED.

Potentially contaminated materials could be
present if remediation is not initiated before or during building reuse.
See Toxicologic Evaluation section.

Can not determine whether drinking water supplies
were affected in the past if the treatment facility was then unable to cope
with episodic contaminant releases to river water.

Site-related public exposure should not occur.
Could occur only if contaminants migrate to source, and if source is developed
for supply, and if regulatory agencies do not test water and, if contaminated,
do not either terminate use or require treatment or remediation.

NOTE: THE PRESENCE OF A POTENTIAL EXPOSURE
PATHWAY IN THIS LIST DOES NOT IMPLY THAT A POTENTIAL EXPOSURE IS SUBSTANTIVE
OR THAT AN ADVERSE HEALTH EFFECT HAS OCCURRED OR WILL OCCUR.

ATSDR made the public health assessment available for public review and comment in the local
library for a 30-day period ending January 10, 1999. The public comment period was
announced in newspapers and through radio. In addition, the public health assessment was sent
to several individuals and government groups. Page numbers mentioned in this appendix refer
to pagination in the public comment version of the document.

COMMENT:

A state employee comments that the public health assessment does not mention
that a potential public water source (groundwater) exists within 1 mile
of the site and is expected to produce about 1.5 million gallons of potable
water per day, with a maximum of 6 to 8 million gallons of water per day.

Response:

The document has been changed to address that potential
source. ATSDR does not believe that exposure or health effects will
occur. Any potential new water source should be chemically analyzed
before it is developed for use, and all public water supplies have to
be analyzed periodically while being used. If the water is shown to
be contaminated by site-related or other chemicals, regulatory agencies
should require appropriate treatment and/or remediation.

COMMENT:

A state employee comments that fish evaluated 15 miles downstream do not
constitute a representative sample of fish in proximity of the site, and
recommends that fish should be evaluated for subsistence and recreational
consumption for a sample that is more representative of the site.

Response:

ATSDR agrees that fish evaluated 15 miles downstream are not necessarily
representative of fish in proximity of the site. However, ATSDR believes
that sampling of the fish near the site is not warranted.

During early Bemberg operations, some industrial wastes and wastewater
were discharged into the water without treatment, and fish kills occurred.
It is possible that fish then being consumed contained some site-related
chemicals, which were then conveyed to people that ate them. Sampling
data are not available for fish near the site for that time period,
hence the potential for that exposure cannot be evaluated.

For the latter part of the plant's operations, wastes were handled
on site in a lagoon and landfill, and a wastewater plant treated effluent
discharged to the river. Bemberg stopped production and discharges
more than 20 years ago. An adjacent rayon plant, which treated its
effluent in that plant, also has terminated operations. Thus, there
are no ongoing rayon processing discharges. Several river water and
sediment samples taken in 1991 do not show elevated contamination.
These factors lead us to conclude that there is very little likelihood
that fish being caught now contain any significant site contaminants.
Thus, fish sampling is not warranted.

COMMENT:

A state employee commented that there is approximately 140,000 cubic yards
of copper sulfate in the former landfill which has not been addressed in
the public health assessment.

Response:

The document will be modified to clarify this issue. The second
paragraph of Page 2 says that the landfill was closed and capped
with soil in 1984 in accordance with regulatory requirements.
That same paragraph says that the lagoon was closed and filled
with soil in 1984 in accordance with requirements. The first full
paragraph of Page 3 states that the city will allow only surface-type
uses within the closed landfill and pond areas (e.g., no basements
or excavation) because of underlying contaminated material.

ATSDR does not believe that exposure to copper sulfate (or any
other materials) in the landfill or health effects are likely
to occur. Because of the closure methods and the city's commitments
to allow only surface-type future development within the landfill
and lagoon areas, ATSDR believes that humans are not likely to
come in direct contact with the buried waste material. Current
public water supplies are not likely to be affected by any waste
releases to underlying site groundwater. Should site releases
migrate to any current source of drinking water, or to the potential
water source addressed in Comment 1, ATSDR believes that regulatory-mandated
testing of water supplies, and treatment (or remediation, if required)
should protect the public from exposure and health consequences.